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1
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2
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- a. Which patient populations are
strongly recommended for inclusion at the time of initial approval? In
particular, comment on:
- stage of disease (compensated and decompensated cirrhosis)
- treatment experience (naïve and interferon+ ribavirin experienced)
- genotype (1 and 4 or 2 and/or 3 or some other grouping)
- co-morbidities (HIV and/or HBV co-infection)
- pre and post liver transplantation
- pediatrics
- racial and ethnic groups
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3
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- b. For the purposes of pursuing an indication for novel agents in
treatment experienced non responder patients please comment on the
following components as inclusion criteria in clinical development
studies
- Previously treated with 1 or more IFN-containing regimens that include
PEG-IFN and RBV; and
- Failure to achieve a ≥ 2 log reduction in HCV RNA at Week 12, or
HCV detectability at Week 24 or beyond while on therapy (confirmed by a
repeat test); and
- Compliance documented over the first 12 weeks of previous therapy to
confirm receipt of at least 80% of the prescribed RBV and PEG-IFN dose.
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4
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- c. Please discuss whether or not it is appropriate in a clinical trial
of prior interferon
treatment non- responders to study true responders, partial responders and relapsers
together and why.
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5
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- Are placebo controls or delay of initiation of therapy acceptable, and,
if so, of what duration? In your
answer, please consider the following patient populations:
- treatment-naïve versus treatment-experienced
- compensated and decompensated liver disease.
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6
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- Endpoints Compensated Liver Disease
- Considering the patient populations identified in question number 1 and
the necessity that endpoints for registration be clinically meaningful,
please answer the following:
- a. Which primary endpoint (s) should be used in clinical trials? Please discuss histologic, viral and
biochemical endpoints.
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7
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- b. When should the assessment
of the primary endpoint be made?
Please comment on the pros and cons of an SVR 12 (12 weeks
after cessation of treatment) versus SVR 24 (24 weeks after cessation
of treatment).
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8
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- c. If a study has treatment arms of a different duration, when should
assessment of SVR 24 be made?
Specifically, should it be made 24 weeks after end of treatment
for all arms, or 24 weeks after the end of treatment based on the arm
with the longest duration of therapy?
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9
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- d. Please discuss the following study designs
- adding the investigational agent to standard-of-care (SOC)
- use of a dose of PEG-IFN lower than SOC or lower than SOC and of shorter
duration + investigational agent
- ribavirin substitution
- use of two or more investigational agents
- monotherapy
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10
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- e. What degree of change is clinically meaningful for patients with
decompensated liver disease when using change in CPT or MELD score as
an endpoint?
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11
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- Beyond the assessment of the primary endpoint for registration, what is
the appropriate duration of follow-up for chronic hepatitis C infection,
and what kind of information should be gathered? Please discuss duration of follow-up
for different patient populations (especially pediatrics), and, in
particular, when an investigational agent is not added to
standard-of-care.
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